Last updated: March 12, 2026
Digital Clubhouse (“we”, “us”, or “our”) operates the SPAG Buddy mobile application (the “App”). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our App, and the terms under which you may use it.
This policy is designed to comply with the Apple App Store Review Guidelines (including Guideline 1.3 — Kids Category and Guideline 5.1.4 — Kids), the App Tracking Transparency framework requirements, the Children’s Online Privacy Protection Act (COPPA), and applicable data protection regulations including the GDPR.
Part 1 — Privacy Policy
1. Data We Collect
SPAG Buddy collects and processes only the data strictly necessary to provide its core functionality — helping UK primary school students practise Spelling, Punctuation and Grammar through interactive quizzes.
1.1 Data Stored Locally on Your Device
SPAG Buddy stores the following data locally on your device to provide progress tracking:
- Quiz scores — your scores for each of the 43+ SPaG topics
- Progress data — which topics you have attempted and your performance
This data is stored only on your device using the device’s local storage. It is never transmitted to any server, cloud service, or third party. Uninstalling the App removes all stored data permanently.
1.2 Data We Do NOT Collect
We want to be explicit about data we do not collect:
- We do not collect personal information such as your name, email address, or phone number
- We do not require account creation, registration, or login of any kind
- We do not use analytics SDKs, advertising frameworks, or crash reporting services
- We do not collect device identifiers (IDFA, IDFV) for any purpose
- We do not collect location data
- We do not collect health, fitness, financial, or biometric data
- We do not use cookies or similar tracking technologies
- We do not collect browsing history or search history
- We do not use Firebase, cloud databases, or any external data storage services
- We do not collect photographs, videos, or audio recordings
2. How We Use Your Data
Data stored by SPAG Buddy is used solely to:
- Display your quiz scores and progress within the App
- Allow you to track which topics you have practised and how you performed
We do not use your data for advertising, marketing, profiling, or any purpose beyond providing the App’s core functionality. All data remains on your device at all times.
3. Tracking & App Tracking Transparency
SPAG Buddy does not track you as defined by Apple’s App Tracking Transparency (ATT) framework. Specifically:
- We do not link your data with data collected by other companies’ apps or websites
- We do not share your data with data brokers
- We do not use your data for targeted advertising or advertising measurement
- We do not access or use the advertising identifier (IDFA)
Because we do not engage in tracking, the App does not display an App Tracking Transparency prompt.
4. Third-Party Services
No third-party services are used. In accordance with Apple’s Kids Category requirements (Guideline 1.3), SPAG Buddy does not include third-party analytics, third-party advertising, or any other external services. The App contains zero third-party code, libraries, or SDKs. The App does not connect to the internet and operates entirely offline.
5. Data Storage & Security
- All data is stored locally on your device only. No data is transmitted to any server, cloud service, or external system.
- No network connections are made by the App. SPAG Buddy operates entirely offline.
- Quiz progress is stored using the device’s local storage and is accessible only through the App.
- No user data leaves your device at any time.
6. Data Retention & Deletion
SPAG Buddy stores quiz progress locally on your device for as long as the App is installed. To delete all data:
- Uninstall the App — this permanently removes all stored progress and quiz scores
- No residual data remains on any server or cloud service, as no data is ever transmitted from the device
7. Your Rights
You have the right to:
- Access — request confirmation of what data we hold about you (we hold none; all data is stored locally on your device)
- Deletion — remove all data by uninstalling the App
- Withdraw consent — stop using the App at any time
- Enquiry — contact us with any questions about our data practices
To exercise any of these rights, contact us at nathan.shipston2013@gmail.com.
8. Children’s Privacy & Apple Kids Category Compliance
SPAG Buddy is listed in the Apple App Store Kids Category (ages 9–11 band) and is designed for use by UK primary school students studying the Key Stage 2 (KS2) Spelling, Punctuation and Grammar curriculum. As a Kids Category app, we are committed to the highest standards of children’s privacy and comply fully with Apple App Store Review Guideline 1.3 (Kids Category), Guideline 5.1.4 (Kids), the Children’s Online Privacy Protection Act (COPPA), and the children’s privacy provisions of the General Data Protection Regulation (GDPR).
8.1 No Third-Party Analytics or Advertising
In accordance with Apple’s Kids Category requirements, SPAG Buddy does not include:
- Third-party analytics SDKs or services of any kind
- Third-party advertising frameworks or ad networks
- Contextual advertising of any kind
- Crash reporting services or performance monitoring tools
There are no exceptions to this policy. The App contains zero third-party code, libraries, or services.
8.2 No Personally Identifiable Information Sent to Third Parties
SPAG Buddy does not send personally identifiable information or device information to any third party. Specifically:
- No child data (names, identifiers, quiz scores, or any user-generated information) is transmitted to any external service, server, or third party
- No device identifiers (IDFA, IDFV, serial numbers, or hardware identifiers) are shared with any third party
- No network information, device information, or any data that could be used — directly or in combination with other information — to identify users or their devices is transmitted externally
- The App operates entirely offline and makes no network connections whatsoever
8.3 No External Links, Purchasing, or Distractions
In compliance with Kids Category requirements, the App does not include:
- Links that navigate out of the App
- In-app purchasing opportunities
- Advertising or promotional content
- Social media integration or sharing features
- Any content or functionality designed to distract from the App’s core educational purpose
If any such features are introduced in future updates, they will be placed behind an appropriate parental gate in accordance with Apple’s guidelines.
8.4 Data Handled by the App
The only data handled by SPAG Buddy is quiz scores and topic progress, which are:
- Generated within the App based on the child’s quiz answers
- Stored only on the local device
- Never transmitted to any server, cloud service, or third party
- Never linked to any personal identity, account, or identifier
- Fully anonymous — no names, usernames, or identifiable information is associated with the data
8.5 COPPA Compliance
SPAG Buddy is compliant with the Children’s Online Privacy Protection Act (COPPA). The App:
- Does not collect personal information from children under 13 (or under 16 where required by local law)
- Does not require children to disclose personal information as a condition of use
- Does not use persistent identifiers to track children across apps or websites
- Does not contact children or enable children to make personal information publicly available
- Does not require account creation, login, or registration of any kind
8.6 GDPR — Children’s Data Protection
SPAG Buddy complies with the children’s data protection provisions of the General Data Protection Regulation (GDPR) and the UK GDPR. Because the App does not collect, transmit, or process any personal data from children:
- No parental consent is required for data processing, as no personal data is collected or transmitted
- No age verification is required, as no personal data is processed
- The App does not create profiles of children or make automated decisions about children
- All quiz progress data is fully anonymous and stored only on the local device
8.7 Ongoing Commitment
As a Kids Category app, SPAG Buddy will continue to meet all Kids Category requirements in all subsequent updates. Any changes to the App’s data practices will be reflected in this policy before the relevant update is released.
9. International Data Transfers
Because SPAG Buddy does not transmit any data from your device, there are no international data transfers to disclose. All data remains stored locally on your device at all times.
10. Changes to This Policy
We may update this policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the “Last updated” date. You are advised to review this policy periodically.
Part 2 — Apple App Store Data Collection Disclosure
In accordance with Apple’s App Privacy requirements, this section details the data types collected by SPAG Buddy, mapped to Apple’s privacy nutrition label categories.
Data Linked to You
None. SPAG Buddy does not link any data to your identity or Apple ID.
Data Used to Track You
None. The App does not engage in tracking as defined by Apple.
Data Collected
None. SPAG Buddy does not collect any data that leaves your device. Quiz progress is stored locally and is never transmitted.
| Apple Category | Data Type | Collected? | Purpose |
|---|---|---|---|
| Contact Info | Name, email, phone, address | No | — |
| Health & Fitness | Health, fitness data | No | — |
| Financial Info | Payment, credit info | No | — |
| Location | Precise or coarse location | No | — |
| Sensitive Info | Racial, political, religious data | No | — |
| Identifiers | User ID, device ID | No | — |
| Usage Data | App interaction, advertising data | No | — |
| Diagnostics | Crash data, performance data | No | — |
| Other Data | Any other data | No | — |
Summary: SPAG Buddy does not collect, store externally, or transmit any user data. Quiz progress is stored locally on the device and is never sent to any server or third party.
Part 3 — Terms of Use
1. Acceptance of Terms
By downloading, installing, or using SPAG Buddy, you agree to be bound by these Terms of Use. If you do not agree, do not use the App.
2. Description of Service
SPAG Buddy is a free educational mobile application designed for UK primary school students studying the Key Stage 2 (KS2) Spelling, Punctuation and Grammar curriculum. The App provides interactive multiple-choice quizzes across 43+ SPaG topics with progress tracking.
3. Intended Audience
SPAG Buddy is designed for children aged 7–11 (Key Stage 2) and is listed in the Apple App Store Kids Category (ages 9–11 band). The App is suitable for use by children independently or under the supervision of a parent, guardian, or teacher.
4. Your Responsibilities
Parents, guardians, and teachers are responsible for:
- Supervising children’s use of the App as they see fit
- Ensuring the App is used in accordance with any school or institutional acceptable use policies
- Contacting us with any concerns about the App’s content or functionality
5. Educational Content
The quiz content in SPAG Buddy is aligned to the UK National Curriculum for Key Stage 2. While we strive for accuracy, the App is intended as a supplementary learning tool and should not be used as a sole educational resource. We make no guarantees about educational outcomes.
6. Intellectual Property
The App, including its design, code, questions, and content, is the property of Digital Clubhouse and is protected by intellectual property laws. You are granted a limited, non-exclusive, non-transferable licence to use the App for its intended educational purpose.
7. Limitation of Liability
To the fullest extent permitted by law, Digital Clubhouse shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from your use of the App, including but not limited to loss of progress data or service interruptions.
The App is provided “as is” and “as available” without warranties of any kind, whether express or implied.
8. Termination
You may stop using the App at any time by uninstalling it. We reserve the right to suspend or terminate access to the App at our discretion.
9. Changes to Terms
We may modify these Terms at any time. Continued use of the App after changes constitutes acceptance of the revised Terms.
10. Governing Law
These Terms shall be governed by and construed in accordance with the laws of England and Wales.
Contact Us
If you have any questions about this Privacy Policy, Data Collection practices, or Terms of Use, please contact us:
Digital Clubhouse
Email: nathan.shipston2013@gmail.com
Website: digitalclubhouse.org